FISMA Compliance: A Complete Guide to Navigating Low, Moderate, and High Levels

The Federal Information Security Modernization Act (FISMA) establishes a comprehensive strategy for enhancing the cybersecurity posture of federal agencies. The categorization of impact levels within this framework, as elucidated by FIPS-199, emerges as a linchpin. It is a structured approach to evaluating and quantifying the potential consequences of security incidents, laying the groundwork for robust security controls tailored to federal entities’ unique needs and challenges.

Understanding and implementing the impact level categorizations outlined in FIPS-199 is not just a compliance requirement but a strategic imperative for safeguarding sensitive information within the federal government’s purview. This introductory guide aims to unravel the intricacies of this categorization process, shedding light on its significance and practical implications for federal information security protocols.

The impact level categorizations defined in the context of FISMA standards compliance, particularly as outlined in FIPS-199, were established by the National Institute of Standards and Technology (NIST). NIST is a non-regulatory agency of the U.S. Department of Commerce responsible for developing and promoting standards and guidelines to enhance the security and interoperability of information systems.

FISMA Compliance: A Complete Guide to Navigating Low, Moderate, and High Levels

Background to FISMA

The need for standardized categorization of information and information systems based on impact levels emerged from recognizing that not all systems and information have the same value or require security protection. To address this, NIST developed FIPS-199, “Standards for Security Categorization of Federal Information and Information Systems.”

FIPS-199 was first published in February 2004. It established a framework for categorizing information and information systems into Low, Moderate, and High-impact levels. The impact levels are determined based on the potential impact of the loss of confidentiality, integrity, and availability of the information.

Key Points about FIPS-199

  • Categorization Process: FIPS-199 provides a systematic process for federal agencies to categorize information and information systems. The process involves assessing the impact of potential security incidents and determining the appropriate impact level.
  • Security Objectives: The categorization process helps agencies identify the security objectives (confidentiality, integrity, and availability) most critical for their information and systems.
  • Basis for Security Controls: Once information and systems are categorized, agencies use the assigned impact level to select and implement security controls. NIST Special Publication 800-53, “Security and Privacy Controls for Federal Information Systems and Organizations,” complements FIPS-199 by providing a catalog of FISMA controls for different impact levels.

FISMA Compliance

FISMA, enacted in 2002, incorporated the principles outlined in FIPS-199 into its framework. The FISMA regulation mandates that federal agencies follow a risk-based approach to information security, including categorizing their information systems based on FIPS-199 guidelines. This categorization and implementing appropriate security controls are crucial for achieving FISMA compliance.

Examples of FIPS 199-Based Selection of Impact Levels

FIPS-199 provides a structured framework for categorizing information and information systems based on the potential impact of a loss of confidentiality, integrity, and availability. The following examples illustrate how security objective impact assessments can lead to the categorization of different types of information.

EXAMPLE 1: Public Information on a Web Server

An organization managing public information on its web server assesses the impact levels as follows:

  • No potential impact from a loss of confidentiality.
  • Moderate potential impact from a loss of integrity.
  • Moderate potential impact from a loss of availability.

The resulting security category for this information type is expressed as:

“Security Category public information = {(confidentiality, n/a), (integrity, moderate), (availability, moderate)}.”

EXAMPLE 2: Sensitive Investigative Information in Law Enforcement

A law enforcement organization managing susceptible investigative information evaluates the impact levels as follows:

  • High potential impact from a loss of confidentiality.
  • Moderate potential impact from a loss of integrity.
  • Moderate potential impact from a loss of availability.

The resulting security category for this type of information is expressed as:

“Security Category investigative information = {(confidentiality, high), (integrity, moderate), (availability, moderate)}.”

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EXAMPLE 3: Routine Administrative Information in a Financial Organization

A financial organization managing routine administrative information (not privacy-related) determines the impact levels as follows:

  • Low potential impact from a loss of confidentiality.
  • Low potential impact from a loss of integrity.
  • Low potential impact from a loss of availability.

The resulting security category for this information type is expressed as:

“Security Category administrative information = {(confidentiality, low), (integrity, low), (availability, low)}.”

In the context of FIPS-199 and determining the security category for an information type or system, the overall security category is often determined by the highest impact level among the three security objectives (confidentiality, integrity, and availability).

The idea is that the security category should reflect the most significant potential impact. For example, suppose a system has a high potential impact on confidentiality but only a low potential impact on integrity and availability. In that case, the overall security category is considered high because the highest impact level is high.

This approach ensures that the security controls and measures align with the most critical security objective. However, it’s important to note that each security objective is assessed independently, and the highest category approach is used to guide the overall security categorization.

Security Categories in a Table

FIPS 199 introduces security categories for both information and information systems based on the potential impact on an organization in the event of certain events. These events could compromise information and information systems critical for accomplishing the organization’s mission, protecting assets, fulfilling legal responsibilities, maintaining day-to-day functions, and safeguarding individuals.

Security categories align with vulnerability and threat information, aiding in the assessment of risk to an organization. Three potential levels of impact (low, moderate, and high) are established for each security objective: confidentiality, integrity, and availability.

FIPS 199 Defines Three Levels of Potential Impact

Potential ImpactDefinitions
LowLimited adverse effect on organizational operations, assets, or individuals
ModerateSerious adverse effect on organizational operations, assets, or individuals
HighSevere or catastrophic adverse effect on organizational operations, assets, or individuals

In FIPS 199, the security category of an information type is associated with both user and system information, applicable to electronic or non-electronic forms. It serves as input for determining the appropriate security category for a system. 

Understanding FISMA Impact Levels

FISMA impact levels, classified as High, Moderate, and Low, play a pivotal role in tailoring security controls to the inherent risk associated with different types of information. Let’s delve into each level to grasp their significance.

High-Impact Systems

High-impact systems are at the pinnacle of the FISMA hierarchy, dealing with classified and susceptible information. The stringent security measures imposed on these systems encompass robust encryption and multifactor authentication (MFA).

The emphasis on safeguarding against unauthorized access, disclosure, or modification of critical data underscores the gravity of securing these environments.

Moderate Impact Systems

Moderate-impact systems strike a balance, handling sensitive but unclassified information. The security controls for these systems are comprehensive, addressing the need for protection without the extreme measures required for High-impact systems. MFA and encryption remain crucial, but the overall approach is nuanced to align with the moderate risk associated with the data.

Low-Impact Systems

Low-impact systems, managing information that is not sensitive, are subject to fewer security controls. While the emphasis on foundational security practices persists, the FISM compliance requirements are less stringent than higher impact levels. This acknowledges the varying degrees of risk across federal information systems.

Security Categorization Process Guide

Step 1: Identify Information Systems

Understand the organization’s functions and goals by documenting business and mission areas.

Identify the various information types handled and break down functions into manageable sub-functions.

Step 2: Identify Information Types

Choose potential impact levels for confidentiality, integrity, and availability. Categorize each information type based on the chosen impact levels.

Step 3: Select Provisional Impact Levels

Review and adjust impact levels considering organizational, environmental, and legal factors.

Step 4: Review Provisional Impact Levels

Examine and modify security categorizations based on aggregate information types. Determine the overall security categorization for the information system and adjust the highest impact level if necessary.

Simplify FISMA Compliance

At Centraleyes, we recognize the critical importance of FISMA compliance and its integral role in protecting sensitive information within federal agencies. Our comprehensive suite of solutions is designed to streamline the compliance process, providing agencies with the tools and insights needed to achieve and maintain compliance effectively.

Whether navigating the intricacies of impact-level categorization or annual FISMA reporting, Centraleyes is committed to empowering federal agencies with the resources and support they need to safeguard their digital assets and uphold the highest cybersecurity standards.

Contact us today to learn more about how Centraleyes can support your FISMA compliance efforts and ensure the security and integrity of your digital infrastructure.

Start Getting Value With
Centraleyes for Free

See for yourself how the Centraleyes platform exceeds anything an old GRC
system does and eliminates the need for manual processes and spreadsheets
to give you immediate value and run a full risk assessment in less than 30 days

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